Our Global Regulatory Enforcement colleagues Judy Harris and Jack Gindi recently wrote two blog posts on the TCPA. One discusses the FCC possibly gearing up to issue some guidance on what constitutes an automatic telephone dialing system (“auto-dialer”) under the TCPA. The other is related to today’s effective date of the FCC’s earlier revision of its TCPA rules, which includes a requirement that prior express written consent be obtained “for all autodialed or prerecorded telemarketing calls to wireless numbers and residential lines.” This post is meant as a reminder of this new requirement.
Judith L. Harris is a partner in the Washington, DC office of Reed Smith and was a former Managing Partner of that office. She was head of the Office of Legislative and Intergovernmental Affairs at the Federal Communications Commission in the Clinton Administration and earlier in her career, served as a Senior Trial Lawyer in the Antitrust Division of the Justice Department. Judy’s practice is currently concentrated on competition, consumer protection and regulatory issues before the FCC, the FTC and the DOJ, as well as on Capitol Hill. She also devotes much of her time to issues of Internet governance, including matters relating to ICANN and its ongoing creation of new gTLDs (the letters to the right of the dot in an Internet address).
Travis P. Nelson is an attorney in the Princeton and New York offices of Reed Smith, and is a co leader of the firm’s Financial Institutions Enforcement & Investigations Team. Travis is formerly an Enforcement Counsel with the Office of the Comptroller of the Currency, U.S. Treasury Department, in Washington, D.C., and regularly advises institutions and their directors and officers on compliance, examinations, and enforcement issues. Travis is also adjunct faculty at Villanova University Law School, where he teaches Regulation of Financial Institutions.